2022-cv-04601

COMPLAINT filed by Steven Rhodes; Filing fee $ 402, receipt number AILNDC-19788336.

Exhibit 1

Exhibit 2

Exhibit 3

(Exhibit 4)

SEALED DOCUMENT by Plaintiff Steven Rhodes Schedule A to Complaint 1

CIVIL Cover Sheet

ATTORNEY Appearance for Plaintiff Steven Rhodes by Keith A. Vogt

ATTORNEY Appearance for Plaintiff Steven Rhodes by Yi Bu

ATTORNEY Appearance for Plaintiff Steven Rhodes by Adam Grodman

ATTORNEY Appearance for Plaintiff Steven Rhodes by Yanling Jiang

CASE ASSIGNED to the Honorable Andrea R. Wood. Designated as Magistrate Judge the Honorable Jeffrey T. Gilbert. Case assignment: Random assignment.

CLERK'S NOTICE: Pursuant to Local Rule 73.1(b), a United States Magistrate Judge of this court is available to conduct all proceedings in this civil action. If all parties consent to have the currently assigned United States Magistrate Judge conduct all proceedings in this case, including trial, the entry of final judgment, and all post-trial proceedings, all parties must sign their names on the attached Consent To form. This consent form is eligible for filing only if executed by all parties. The parties can also express their consent to jurisdiction by a magistrate judge in any joint filing, including the Joint Initial Status Report or proposed Case Management Order.

MOTION by Plaintiff Steven Rhodes for leave to file [Certain] Document Under Seal

MEMORANDUM In Support of 9 Ex Parte Motion

Declaration of Keith A. Vogt

(Exhibit 1-2, Declaration of Keith Vogt)

Notice of Motion for presentment of Ex Parte Motion 9, motion for leave to file 8 NOTICE of Motion by Keith A. Vogt for presentment of motion for leave to file 8 before Honorable Andrea R. Wood on 8/31/2022 at 10:45 AM.

MINUTE entry before the Honorable Andrea R. Wood: Plaintiff's motion for leave to file under seal 8, and ex parte motion for leave of expedite discovery and electronic service of process pursuant to Fed. R. Civ. P. 4(f)(3) 9 are set for a telephonic hearing on 8/31/2022 at 10:45 AM. To ensure public access to court proceedings, members of the public and media may call in to listen to telephonic hearings. The call-in number is (888) 557-8511 and the access code is 3547847. Counsel of record will receive an email 30 minutes prior to the start of the telephonic hearing with instructions to join the call. Persons granted remote access to proceedings are reminded of the general prohibition against photographing, recording, and rebroadcasting of court proceedings. Violation of these prohibitions may result in sanctions, including removal of court-issued media credentials, restricted entry to future hearings, denial of entry to future hearings, or any other sanctions deemed necessary by the Court.Mailed notice

MAILED copyright report to Registrar, Washington DC.

MINUTE entry before the Honorable Andrea R. Wood: Telephonic motion hearing held on 8/31/2022. For the reasons stated on the record, Plaintiff's motion for leave to file under seal 8, and ex parte motion for leave of expedite discovery and electronic service of process pursuant to Fed. R. Civ. P. 4(f)(3) 9 is taken under advisement. A continued telephonic motion hearing is set for 9/14/2022 at 10:15 AM. To ensure public access to court proceedings, members of the public and media may call in to listen to telephonic hearings. The call-in number is (888) 557-8511 and the access code is 3547847. Counsel of record will receive an email 30 minutes prior to the start of the telephonic hearing with instructions to join the call. Persons granted remote access to proceedings are reminded of the general prohibition against photographing, recording, and rebroadcasting of court proceedings. Violation of these prohibitions may result in sanctions, including removal of court-issued media credentials, restricted entry to future hearings, denial of entry to future hearings, or any other sanctions deemed necessary by the Court. Mailed notice

MINUTE entry before the Honorable Andrea R. Wood: Telephonic motion hearing held on 9/14/2022. For the reasons stated on the record, Plaintiff's motion for leave to file under seal 8, and ex parte motion for leave of expedite discovery and electronic service of process pursuant to Fed. R. Civ. P. 4(f)(3) 9 are granted. Enter Order. The Clerk is directed to maintain Schedule A to the complaint 2 under seal until further order of this Court. Telephonic status hearing set for 10/14/2022 at 10:00 AM. To ensure public access to court proceedings, members of the public and media may call in to listen to telephonic hearings. The call-in number is (888) 557-8511 and the access code is 3547847. Counsel of record will receive an email 30 minutes prior to the start of the telephonic hearing with instructions to join the call. Persons granted remote access to proceedings are reminded of the general prohibition against photographing, recording, and rebroadcasting of court proceedings. Violation of these prohibitions may result in sanctions, including removal of court-issued media credentials, restricted entry to future hearings, denial of entry to future hearings, or any other sanctions deemed necessary by the Court. Mailed notice

ORDER FOR LEAVE OF EXPEDITED DISCOVERY AND SERVICE OF PROCESS BY E-MAIL AND/OR ELECTRONIC PUBLICATION. Signed by the Honorable Andrea R. Wood on 9/14/2022.

SUMMONS Issued as to Defendant The Partnerships and Unincorporated Associations Identified on Schedule "A"

SUMMONS Returned Executed by Steven Rhodes as to The Partnerships and Unincorporated Associations Identified on Schedule "A" on 9/28/2022, answer due 10/19/2022.

(Declaration of Service)

MINUTE entry before the Honorable Andrea R. Wood: Telephonic status hearing held on 10/14/2022 and continued to 11/2/2022 at 9:45 AM. To ensure public access to court proceedings, members of the public and media may call in to listen to telephonic hearings. The call-in number is (888) 557-8511 and the access code is 3547847. Counsel of record will receive an email 30 minutes prior to the start of the telephonic hearing with instructions to join the call. Persons granted remote access to proceedings are reminded of the general prohibition against photographing, recording, and rebroadcasting of court proceedings. Violation of these prohibitions may result in sanctions, including removal of court-issued media credentials, restricted entry to future hearings, denial of entry to future hearings, or any other sanctions deemed necessary by the Court. Mailed notice

MOTION by Plaintiff Steven Rhodes for default judgment as to The Defendants Identified In Schedule A

MEMORANDUM by Steven Rhodes in support of motion for default judgment 19

Exhibit 1

Exhibit 2

Declaration of Keith A. Vogt

(Declaration of Steven Rhodes)

NOTICE of Motion by Keith A. Vogt for presentment of motion for default judgment 19 before Honorable Andrea R. Wood on 11/2/2022 at 09:45 AM.

MINUTE entry before the Honorable Andrea R. Wood: Plaintiff's motion for entry of default and default judgment against defendants identified in Schedule A 19 will be heard at the telephonic hearing set for 11/2/2022 at 9:45 AM. Any party wishing to be heard on the motion shall contact the courtroom deputy (laritza_arcos@ilnd.uscourts.gov) for instructions on how to join the call. To ensure public access to court proceedings, members of the public and media may call in to listen to telephonic hearings. The call-in number is (888) 557-8511 and the access code is 3547847. Counsel of record will receive an email 30 minutes prior to the start of the telephonic hearing with instructions to join the call. Persons granted remote access to proceedings are reminded of the general prohibition against photographing, recording, and rebroadcasting of court proceedings. Violation of these prohibitions may result in sanctions, including removal of court-issued media credentials, restricted entry to future hearings, denial of entry to future hearings, or any other sanctions deemed necessary by the Court. Mailed notice

MINUTE entry before the Honorable Andrea R. Wood: Telephonic status and motion hearing held on 11/2/2022. Only Plaintiff appears. The Court enters default pursuant to Fed. R. Civ. P. 55(a) against the defendants. Plaintiff's request for entry of default judgment is taken under advisement. Telephonic status hearing set for 11/16/2022 at 9:45 AM. To ensure public access to court proceedings, members of the public and media may call in to listen to telephonic hearings. The call-in number is (888) 557-8511 and the access code is 3547847. Counsel of record will receive an email 30 minutes prior to the start of the telephonic hearing with instructions to join the call. Persons granted remote access to proceedings are reminded of the general prohibition against photographing, recording, and rebroadcasting of court proceedings. Violation of these prohibitions may result in sanctions, including removal of court-issued media credentials, restricted entry to future hearings, denial of entry to future hearings, or any other sanctions deemed necessary by the Court. Mailed notice

MINUTE entry before the Honorable Andrea R. Wood: Plaintiff's motion for entry of default judgment 19 is granted. Specifically, after a hearing on 11/2/2022 and having considered Plaintiff's motion and supporting materials, the Court grants Plaintiff's request for entry of default judgment as to Defaulting Defendants as follows. The Court previously found that Defaulting Defendants each failed to plead or otherwise defend this action, and thus entry of default pursuant to Fed. R. Civ. P. 55(a) was appropriate. "The basic effect of an entry of default. is that upon default, the well-pleaded allegations of a complaint relating to liability are taken as true." VLM Food Trading Int'l, Inc. v. Ill. Trading Co., 811 F.3d 247, 255 (7th Cir. 2016) (internal quotation marks omitted). The Court now further finds that Defaulting Defendants' infringing conduct was willful. With respect to monetary relief, Plaintiff requests an award of $100,000 in statutory damages under 17 U.S.C. § 504(c)(2) against each Defaulting Defendant. A plaintiff in a copyright infringement case may elect to seek statutory damages in the amount of: (1) not less than $750 or more than $30,000; or (2) if the court finds that the infringement was committed willfully, not more than $150,000. In determining the amount of statutory damages to award in this case, the Court has considered "the difficulty or impossibility of proving actual damages, the circumstances of the infringement, and the efficacy of the damages as a deterrent to future copyright infringement." Chi-Boy Music v. Charlie Club, Inc., 930 F.2d 1224, 1229 (7th Cir. 1991). Based on these factors, the Court awards Plaintiff $100,000 per Defaulting Defendant. Enter Default Judgment Order. As all claims as to all Defendants have now been resolved, this case is closed. Telephonic status hearing set for 11/16/2022 is stricken. Civil case terminated. Mailed notice

DEFAULT JUDGMENT ORDER. Signed by the Honorable Andrea R. Wood on 11/16/2022. Mailed notice

MAILED Copyright report and certified copy of minute order dated 11/16/2022 24 to Registrar, Washington DC.